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The Vernal Ranger District on the Ashley National Forest released the long awaited Grazing on the Marsh Peak and Lakeshore Basin Allotments Environmental Assessment (see LYNX 2/99). From the outset we would like to acknowledge and commend the district's decision to enlarge and close the Lake-shore Basin allotment to sheep grazing.

What this now means is a significant portion of the high bollies on the eastern end of the Uintas are closed to domestic sheep grazing. Combined with the closure almost a decade ago of the Beaver Creek and Burnt Fork drainages on the Wasatch National Forest, this frees a huge area of the eastern portion of High Uintas from grazing by domestic "tamelife."

But not all is perfect! We are concerned with the relatively sedate manner in which the Environmental Assessment (EA) addresses the rest of the adjacent Marsh Peak allotment. The EA notes that only a tiny portion of the allotment, about 13%, is suitable for grazing (that alone tells us the allotment is not conducive to grazing in the first place) and that the deferred-rotation grazing system has resulted in a stable trend... in satisfactory vegetative condition.

From an ecological perspective, a stable trend of satisfactory condition is not exactly a positive statement. Of course, there is no such thing as a stable trend toward satisfactory. That kind of language seems very obscure, almost seeming to deflect from what is obviously a benign ecological condition.

What the EA notes is that under the no grazing alternative, vegetation condition (no matter how it is defined) would be improved faster than under any of the restricted grazing alternatives.

The same holds true with respect to impacts upon the "sensitive resources and areas" identified in the EA, e.g. riparian areas, stream condition, soils, fisheries and roadless areas.

The EA notes that impacts to water quality are best resolved with the no grazing alternative. The EA notes that even the no grazing alternative does not assure an adequate buffer between bighorn sheep and domestic sheep. Years of research have shown domestic sheep transmit dozens of lethal pathogens to bighorn sheep which have simply not developed resistance to these modern tame sheep! It also notes that even where proper buffer zones exist, bighorn sheep have experienced domestic sheep disease- related die-offs. Thus the EA tends to downplay the need for the buffer zones.

However, these buffer zones (a minimum of 9 miles) represent a virtual consensus recommendation among bighorn researchers and veterinarians. A complete end to domestic grazing on the Marsh Peak allotment moves management in the right direction-- that indicated by the buffer zone recommendations. They add distance, security and safety.

The "Social Economics" analysis is similarly lacking. The EA makes the mistake of simply looking at "revenues lost" rather than a true benefit/cost analysis which also tabulates costs to the environment, other users opportunity costs, and management costs. Grazing fees certainly don't come close to covering the costs of management of these allotments. To suggest the possibility of lost revenues on the Lakeshore Basin Allotment is a bit of a stretch; there has been no grazing for well over a decade!

The no grazing alternative is the superior alternative from every multiple-resource aspect, with the single exception of grazing. And the Forest Service has erred in assuming that it has the responsibility to provide grazing opportunities even though the impacts upon National Forest resources are notably less without grazing..

Dick Carter

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